SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Mail Stop 3561

      							July 28, 2005

VIA INTERNATIONAL MAIL AND FAX  011-852-2121-3205

Mr. Alexander A. Lutsky
Chief Accountant (CFO)
OISC Long Distance and International Telecommunications Rostelecom
14, 1st Tverskaya-Yamskaya Street
125047 Moscow
Russian Federation

	Re:	Rostelecom
      Form 20-F for Fiscal Year Ended December 31, 2004
		Filed June 29, 2005
		File No.  1-14748

Dear Mr. Lutsky:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Where indicated, we think you should
revise your documents in response to these comments.  If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 20-F for Fiscal Year Ended December 31, 2004

Investment Policy Highlights, page 23

1. We note that you have planned to phase out your analog trunk
lines
which, per your disclosure on page 29, consisted of 15,810 lines.
Tell us your consideration of paragraph 8 of FAS 144.  Also tell
us
why the estimated lives of these lines were not revised under US
GAAP.

Restatement of Historical Financial Statements, page 56

2. We note that you recognize revenue "when it is probable that
the
economic benefits associated with the transaction will flow to the
enterprise and the amount of the revenue can be reliably
measured."
We further note your disclosure here that prior to the
restatement,
you "recognized revenues and expenses related to intercity and
international telephone services based on the difference between
actual billings and actual traffic. This adjustment resulted in a
build-up of an unbilled receivable ..., the realizability of which
could not be assured ... in the absence of clear regulatory and
contractual guidelines."   Tell us why your accounting is
appropriate
under US GAAP and include in your response references to the
appropriate accounting literature.  Also tell us how you
determined
the actual billings. In this connection,

* in light of your decision to record revenues based on actual
billings, tell us how you concluded that you have recorded, in
revenue, all amounts that are realized or realizable and earned.
Refer to Topic 13.A.1 of SAB 104.

* Describe the unclear regulatory and contractual guidelines that
preclude recognition of  actual traffic into revenues.

* Tell us how you intend to account for any unrecorded unbilled
traffic as of the 2004 balance sheet date and if any amount is
subsequently realizable or measurable, pending further resolution.

* Additionally, tell us how you accounted for unbilled (but
potentially billable) traffic occurring between the billing cutoff
date and the balance sheet date as well as the related costs.

* Tell us if you expect to revise your basis for revenue
measurement
as a result of the implementation of the Unified Billing System
(UBS).  We note your disclosure on page 23 that the new system is
expected to improve the precision of settlements between operators
and automate the traffic routing process.

Novation Agreements, page 102

3. Tell us the US GAAP accounting impact, if any, which arose from
the substitution of your lease obligations into borrowings under
the
Novation Agreements and the related transfer of assets.

Note 12. Accounts Receivable, Net. Page F-29

4. Tell us the nature of the accounts receivable written off in
the
amount of RUR 774 million.

Note 18. Interest-bearing loans, page F-34

5. We note that the Government, which has a significant ownership
in
you through Syzainvest, forgave and wrote off fines and penalties
related to your overdue debt that resulted in a gain of RUR 752
million.  Tell us your consideration of SAB Topic 5.T.

Note 23. Discontinued Operations, page F-39

6. Tell us how you accounted for Westelcom`s purchase of RTC-
Leasing`s rights under the Novation Agreements for RUR 368
million.
We note that you were obligated to pay RUR 2,311 million to RTC-
Leasing in 2038.

7. Tell us the nature of the differences in the amounts paid to
RTC-
Leasing as reported in this section and in "Second Amended Lease
Agreements" on page 102.  Also tell us the amount recorded in the
financial statements.

Note 36. New US GAAP standards adopted in 2004, page F-57

8. We note that your investment in GlobalTel is accounted for
under
the equity method.  For US GAAP purposes, tell us how you
concluded
that this investment is not required to be consolidated under
paragraph 5 of FIN 46R.

Note 36. Statement of Shareholders` Equity, page F-60

9. We note that you are required to maintain a reserve fund
through
mandatory annual transfers of at least 5% of your statutory net
profits.  Separately present this reserve in your statement of
shareholders` equity.  See paragraph 15 of FAS 5.

*    *    *    *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Please file your response
letter
via EDGAR. Detailed cover letters greatly facilitate our review.
Please understand that we may have additional comments after
reviewing your amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      You may contact Kathryn Jacobson, Staff Accountant, at (202)
551-3365 or Dean Suehiro, Senior Staff Accountant, at (202) 551-
3384
if you have questions regarding comments on the financial
statements
and related matters.  Please contact me at (202) 551-3810 with any
other questions.

								Sincerely,

								Larry Spirgel
								Assistant Director
??

??

??

??

Mr. Alexander Lutsky
Rostelecom
July 28, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>